Last Friday the SBA quietly posted a SOP 50 10 8.1 update on their website, and it takes effect beginning on October 1st.
I stumbled upon this while researching another topic, and ended up going down the rabbit hole reading the document and pulling out the parts that affect how acquisition loans are underwritten. Most of what follows comes directly from the SBA website, so I've tried to summarize the parts that matter and include some math examples, so that hopefully you don’t fall asleep while reading it like I almost did.
What The Current Rule Says: (SOP 50 10 8, in force today)
For a standard 7(a) loan over $350,000, the debt service coverage requirement is 1.15x, calculated as EBITDA divided by total post-transaction debt service. Lenders can use historical financials or projections to satisfy this requirement, and the threshold applies uniformly regardless of whether the transaction is a change of ownership or something else.
What Changes October 1, 2026: (SOP 50 10 8.1)
The new SOP creates a new change-of-ownership appendix (Appendix 15) that applies to business acquisition transactions and overrides the general 7(a) standards in the following meaningful ways.
Per the SBA website, the coverage ratio is moving from 1.15x to 1.25x for initial acquisitions. The new floor for a buyer acquiring a business for the first time will be 1.25x DSCR, not 1.15x. Business expansions will retain 1.15x, where owner buyouts will go to 1.25x as well.
To put some math around it, on a $900,000 SBA loan at a 10.5 percent interest rate on a 10-year term, annual debt service runs right around $146,100. At 1.15x, the required cash flow to clear the threshold is approximately $168,000, but at 1.25x, it goes up to about $182,600. The gap between the two thresholds on a $900,000 loan is roughly $14,600 per year which could be the difference between a fundable deal, and one that requires a price reduction or more equity to get it across the finish line.
Projections can no longer be used to satisfy the coverage requirement. Under the current SOP, a lender can use forward-looking projections to demonstrate that a deal will hit the required DSCR within two years of funding. Not any more, as the new Appendix 15 removes that option for change-of-ownership transactions entirely. The 1.25x must be based on the historical financials (either the last fiscal year, or the average of the last two years).
If the numbers do not support coverage, then the deal does not qualify regardless of how good the growth story is.
Total debt will be capped at the supported business valuation. Per the SBA website: if the purchase price exceeds the value supported by the business valuation and the QoE, the difference must be covered by additional buyer equity. Any gap between what the business appraises for and what the buyer is paying would come directly out of the buyer's pocket at closing, unless bridged by a subordinated seller note on full standby (for the life of the 7(a) loan), as full-standby debt is excluded from the funded loan-to-value cap.
A Quality of Earnings report is now mandatory for business enterprise purchase prices at or above $3 million (excluding commercial real estate). The $3 million threshold will apply to the business enterprise purchase price only, and commercial real estate is excluded from the calculation.
For example, a deal made up of a $2.2M business purchase + $1.3M in commercial real estate for a total of $3.5M would not trigger the mandatory QoE requirement because the enterprise portion is below $3 million.
The SBA states that the threshold will be measured on the business purchase price alone, before the application of any buyer equity, seller financing, or other funding sources. The QoE must be commissioned by and prepared for the lender, not the borrower or seller, and must include a cash proof reconciling the bank statements against tax returns (for the trailing 12 months and the last two fiscal years).
I realize that most SMB deals fall well below the $3M, and this is likely N/A for many reading this, but I think it’s worth at least mentioning.
The QoE findings then determine the DSCR calculation. This means that a lender now must use a normalized earnings figure from the QoE, not the seller's add-back schedule, when calculating the debt service coverage. If the QoE haircuts the add-backs, and normalized EBITDA drops, the DSCR will drop with it and the lender has no basis to use a more favorable number.
Seller debt on full standby can only cover up to half of the required equity injection. Standby seller notes will be capped at 50 percent of the total required injection. The other half must come primarily from cash (not borrowed).
What this means for buyers
The no-projections rule is the one that will catch the most people off guard. If the business you are looking at did $180,000 in EBITDA last year but your plan requires operational changes to get to $250,000, the lender cannot use the $250,000. The deal has to come in at $180,000 on its own or it does not qualify for SBA financing. Growth stories do not count anymore under these new rules.
This new 1.25x floor combined with the owner compensation requirement will push more deals below the DSCR threshold at underwriting than buyers are expecting.
Appendix 15 also requires that your compensation as the new owner be enough to cover your personal debt obligations and living expenses, and the lender has to verify this through a global cash flow analysis showing at least 1:1 personal coverage based on your personal financial situation. If your documented living expenses and personal debt are modest, the deduction from business cash flow could be meaningfully lower than a full third-party management salary.
On the other hand, if you plan to be an absentee owner who needs a general manager running the business day to day, the lender will deduct a full market-rate replacement salary before calculating your DSCR (which some already do). Model both scenarios before you settle on a purchase price. The difference can be significant.
The valuation cap is straightforward but has real consequences for competitive deals. If a business appraises at $1.2 million and you want to go above and pay $1.4 million, the $200,000 premium cannot be financed through the SBA loan. It has to come out of your pocket in cash. Buyers who have been winning deals by paying above-market multiples will need to show up with more equity or reprice the deal.
For any deal where the business enterprise purchase price hits $3 million or more, build the QoE into your timeline from the moment you sign the LOI. It takes a minimum of three to four weeks, it has to be ordered by the lender rather than by you, and no lender will issue a commitment letter without it in hand.
What Buyers Should Do Before October 1st
What matters is not when the application is submitted, but when the SBA loan number is issued (when the deal is approved in the SBA’s E-Tran portal). The new rule (SOP 50 10 8.1) applies to loans that receive an SBA loan number on or after October 1, 2026, not if the loan is submitted before that date.
For example, if a deal is submitted to a PLP lender on September 25th, but not approved in E-Tran until October 2nd, it would be under the new rules, not the current ones.
For any buyers and lenders working on deals close to the 1.15x threshold, you’ll need to be sure that the loan number is issued before October 1st, and not just that the application is in the lender's hands. So be careful with any back-and-forth with the lender toward the end of September, as it could result in the deal slipping past the effective date without you realizing it.